- 3 -
limitations on assessment bars respondent’s determinations for
each year at issue.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. We
incorporate by this reference the stipulation of facts,
supplemental stipulation of facts, and attached exhibits.
Petitioners Manuel Karcho and Margaret Karcho are husband and
wife who resided in Southfield, Michigan, at the time they filed
their petition. Petitioners filed joint returns for the years in
issue.
Mr. Karcho had emigrated from Iran at age 12 and had very
little formal education. Mrs. Karcho, who emigrated from Malta
at age 11, completed a high school education in the United States
and during the years in issue was employed as a membership and
billing system analyst for a health insurance provider.
During the years in issue Mr. Karcho, through his wholly
owned S corporation, Banner Amusement Enterprises, Inc. (Banner),
owned and operated an amusement arcade called the Space Station.
Mr. Karcho had previously been employed as a manager of the Space
Station before purchasing all of the stock of Banner in 1985 for
$25,000 in cash and a $25,000 note to the seller. Mr. Karcho
continued to manage the operations of the arcade during the years
in issue, with some part-time help. The arcade was open 7 days a
week.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011